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Home My WebLink About00-01736 .. -- -- ;:?.,~;~~~+.': ;~.e;_~;~!4~~:::;.~.}~~':~r.:~;:";':3};::~~3}:':~~t4:<}'::.~~:::~~3XX"}: :;':~::~':';':::<<<:~~3}<,::;~~::<~:~::.}::. ::~::.::+~:X.::. ';~::X.'xx.J:~r;~~}t::K.~~,:;':.~;~tK.j~':::~~jK}~~5._10j;" ~ ~ ~.,~ ~ ,"., ~ ~ ;0;: ~ :,,0,;' ',," "Ii ~ ~) ~ ~~ "'~ ~ ~.'! "~ tI. ~.~ ?-.~. r.1 ~.~ i x IN THE COURT OF COMMON PLEAS $ OF CUMBERLAND .~ COUNTY ',,' ~ ~ '.' STATE OF PENNA. ~ ~ ~: ~ ~.~ ~.~ ~ ~ ~ ~.) ~ ~) r.1 M N ~ e ~ ". ~ jo;'" ~ MARK K. KIOlMAN ..................................................................................... II II II No. .~9.9.Q::-.9.n}~ c::LYiJ........ 19 Versus ........J.OXCE..M.L~;J:~... DECREE IN DIVORCE ~~ ~ ~.~ .-:'" ,~'. ~ ,<'", ;...~ r.1 ~.~ M r.1 >t ~.~ ~ (j ~ ~.~ :""~ ~ ,'"', ;..~ ~ ;; ~ ~~ ~f ~ ~ ,<'".; I N ~~ ~ ;.< ~ (~ 'f.":.. " .'", ~ "'.<( i ~~ ~ -.... ~ ? '''t"'\.,/',,!; . ."'----- - L~~:~,~~~~~~~~~~,~~~.~ AND NOW, . . . ;r. "'.\lS. :7. . .. . . .. . . . . . . ., . ..z.~."'9, it is ordered and decreed that... ., .. .. ~~. ~.'. ~!~. ... . .... .. ., .. .. .. .. .. . '. plaintiff, and . .. . . . . .. . . . . . . . . . .'~q,,:c;E; .~'. .~~~ .. . . . . . . .. . . .. . . . . . .. " defendant, are divorced from the bonds of matrimony. The court retains jurisdiction of the following claims which have been raised of record in this action for which a final order has not yet been entered; ::6'~c;"Q:t41'mmj Prothonotary .::+;. '::+::', :-::+::":>::+::';,.:.::+;',.:'::+::'::::'::+::':,.:'-::+::- ,.::.::....:..::e-::<:'.::.::. ',,' a ~:~ ~ "'+"- r.1 ~~~. ~ ~.~ ~ ~ ~ ~{ >~ ~ n ~ iii n ..'~ ~ ~.~ ~ ~{ ~ ~.~ ~ ~.~ ~ n ", ~ ~'- ~.~ !II ~~ ~ (.~ ~ ~.~ >,,' ,', ~ .'. '." r.1 ~.) ~ ~.~ ~ ~.~ ~ ... ~ ',,' ~ ~.~ '. ~ ,', ~ ~ ~ '.' ~ v ~ .' ~ :.-::.::~: . "'(~ ~~ .'~ '. . , .: ~ ~.. .,4,. tp.).CJ?J M-~~~;4 ~ ~-7-co 71~ ~ -z;- ~ ~ .....< '. Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MARK K. KICHMAN, : vs. : CIVIL DIVISION - LAW IN DIVORCE JOYCE M. KICHMAN, Defendant : : No. 2000-01736 PRAECIPE TO TRANSMIT RECORD 1. Ground for divorce: irretrievable breakdown under Section 3301(d) of the Divorce Code. 2. Date and manner of service of the complaint: March 24, 2000; personal service; Acceptance of Service form filed of record; 3. Complete either (a) or (b). (a) Date of execution of the affidavit of consent required by section 3301(c) of the Divorce Code: nla (b)(l) Date of Execution of the plaintiff's affidavit required by Section 3301(d) of the Divorce Code: 5/08/2000 (b)(2) Date of service of the Plaintiff's affidavit upon the Defendant: May 8, 2000; Date of filing of the section 3301(d) affidavit: May 17, 2000; 4. Related claims pending: Neither party has raised any claims or other related issues. 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record, and attach a copy of said notice under section 3301(d)(1)(i) of the Divorce Code: May 8, 2000 personal service; Acceptance of Service form filed of record; 6. Indicate date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached if decree is to be entered under section 3301(c) of the Divorce Code: not applicable OR, date of execution of Waiver of Notice of Intent: nla AND date of filing of Waiver: no~a ?licable I r-> _ rl _~J-~~l A to ney for Plaintiff - .._ <".-1 MARK K. KICHMAN, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND CCUNTY, PENNSYLVANIA : vs. : CIVIL DIVISION - LAW : IN DIVORCE JOYCE M. KICHMAN, : Defendant No. 2000-01736 civil NOTICE OF INTENTION TO REQUEST ENTRY OF SECTION 3301(d) DIVORCE DECREE To: Joyce M. Kichman 390 Pickering Road Phoenixville, PA 19460 Defendant You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the Section 3301(d) affidavit. Therefore, on or after May 28, 2000, the other party can request the court to enter a final decree in divorce. If you do not file with the prothonotary of the court an answer with your signature notarized or verified or a counter-affidavit by the above date, the court can enter a final decree in divorce. A counter-affidavit_which you may file with the prothonotary of the court is attached to this notice. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Lawyer Referral Service of The York County Bar Association The York County Bar Center 137 East Market Street York, Pa 17401 Telephone: (717) 854-8755 ('"" ,....... . ~ <::> ~ 0 <--- .-\ -on] c:: );31 mn"t z .0,\ Z:D ..'Jut 3i~ ;-;zy ~5 -0 ':::t~ ~""-n ~(") J: GB ;;;;g ~ orit ~ ~ ,,,, ::p c.n '-< MARK K. KICHMAN, Plaintiff vs. : IN THE COURT OF COMMON PLEAS : OF YORK COUNTY, PENNSYLVANIA : CIVIL DIVISION -LAW : IN DIVORCE JOYCE M. KICHMAN, Defendant . : NO. (JO' /73h ~ NOTICE TO DEFEND AND CLAIM RlGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for divorce is indignitites or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Court House, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE TIllS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTI! IlELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 MARK K. KICHMAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA VS. : CIVIL DIVISION - LAW IN DIVORCE ; No. ~ - /73(. ~ ru.--.. JOYCE M. KICHMAN, Defendant COMPLAINT COUNT I SECTION 3301( c) OF THE DIVORCE CODE OF 1980 1. Plaintiff is Mark K. Kichman, an adult individual who currently resides at 2 South Front Street, Wonn1eysburg, Cumberland County, Pennsylvania 17043. 2. Defendant is Joyce M. Kichman, an adult individual who currently resides at 390 Pickering Road, Phoenixville, Pennsylvania 19460. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on February 3, 1997. 5. There have been no prior actions for divorce or annulment between the parties hereto. 6. Plaintiff avers that Defendant is not in any branch of the Armed Services. 7. This action is not collusive. 8. The marriage is irretreivably broken. 9. The Plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. 1 WHEREFORE, Plaintiff requests your Honorable Court to enter a Decree in Divorce, divorcing Plaintiff and Defendant from the bonds of matrimony. COUNT II SECTION 330l( d) OF THE DIVORCE CODE OF 1980 10. Paragraphs one through nine of this Complaint are incorporated herein by reference as though set forth in full. 11. The parties are now living separate and apart; at the appropriate time Plaintiff will submit an affidavit alleging that the parties have lived separate and apart for at least two (2) years and that the marriage is irretreivably broken. WHEREFORE, Plaintiff request your Honorable Court to enter a Decree in Divorce, divorcing Plaintiff and Defendant from the bonds of matrimony. Respectfully submitted: Date: BRATIC & PORTKO ~ By: . . . Stephen . Portko, EsqUlre 101 South U.S. Route 15 Dillsburg, PA 17019 (717) 432-9706 J.D. No. 34538 Attorney for Plaintiff 2 VERIFICATION I, MARK KICHMAN, hereby acknowledge that I am Plaintiff in the foregoing Divorce Complaint, that I have read the foregoing, and the facts stated therein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. mV7~ MARK KICHMAN Date: ;;/:3-S-/09 :>- ~ ,'ff -:t- i::: tJD f.r; ~.. - <- ~ ~("-~ ~ ~ ~:,-j>.'! ~ 8;;';; r3}~ 0:..'- Q~ rI, ;\-: J J-i...ih'. <,-, '-' .. (\] <::s:! ~ n it: {, '{"0 ?:." Cl:: "'"';?:. t """ ~r-> a "',-. l,il/JJ '\ ...... cOlt [5 ::;;: \i) ~m .:::::; ~ (j ~ ~ o ~ ~ gJ 0 ~~ i:l~ ~ (;) ..., ~ ~ ~ ~ 4 . 0"> << 8 "... ,rilL.":I"-+ t::~:S ::>....z "'::>,( ~o::s "'''':>< E-< .", z~z "'::>z u::c'" "'....0.. u::> . -0" ~oo~ s-~ 0'" --'" o ..., - ..., i5 """ 000 "...'" """ e:-adi 0000 ...... ;:;: - - ~t: \ LAW OJ?FICES BltATlC & POltT"liO 101 OFFICE CENTER, SUITE A 101 SOUTH U.S. ROUTE 15 DILLSBURG, PENNSYLVANIA 17019 ~ f ) MARK KICHMAN, IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA plaintiff : vs. : CIVIL DIVISION - LAW : IN DIVORCE JOYCE M. KICHMAN, Defendant No. 2000-01736 Civil~ NOTICE TO THE DEFENDANT If you wish to deny any of the statements set forth in this Affidavit, you must file a counteraffidavit within twenty (20) days after this Affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on March 1, 1997 and have continued to live separate and apart for a period of at least two (2) years. 10 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning ~ alimony, division of property, lawyer's fees or expenses if I" do not claim them before a divorce is granted. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 19 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Date: May 8, 2000 ;/)11 ~r-~ Plaintif = -~ 130090580648 .~ i~ -, 4t$ ~ (") c= <"" vm fl.lm ZXI 21:;:: ~5.-:: GO ~O >c:: Z =< --. -_. - <::> <::> :JJ:: "'" -< o " .-1 -r hipd :s;;gj 06 :t:D 0-'-' ZM ~ ~ --l -0 ::!l: ~ => \.D Plaintiff MARK K. KICHMAN, IN THE ~OURT OF COMMO aJMBERLAND COUNTY, PENNS CIVIL DIVISION - LAW vs. : IN DIVORCE JOYCE M. KICHMAN, Defendant : No. 2000-01736 Civil ACCEPTANCE OF SERVICE filed in the above matter. I accept service of Plaintiff's Complaint in Divorce 7 ~ ~;;. i?:;~~:;n# P~/;GOIc?:,~ ;:;4- /l'7'60 {Mailing Address}- Date:~cL-,}t/ woJ , / ..) ......,..'llII , 130090580649 , ;;; c,'." ~ .'f - 1 {~ 1 , ; " -< (") 0 0 c: = -n ~ :J!: ::;:l:u vm :> r:1f7i -< '-';'r- Z::c ..om -"-c;::: -.J ""6 C?5 ~,.:, 9 ~6 v -..i 0':0 :>e;. :;;:: 2M 20 Pc: eN ~ Z => ):> =< CO ~ ~. ... 6' ~ MARK K. KICHMAN, : IN THE COURT OF COMMON PLEAS plaintiff : CiJmbefland-COUnty, PENNSYLVANIA : vs. CIVIL DIVISION - LAW : IN DIVORCE JOYCE M. KICHMAN, : Defendant : No. 2000-01736 Civil 1. Check either j (a) -(b) DEFENDANT'S COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE (a) or (b): I do not oppose the entry of a divorce I oppose the entry of a divorce decree [Check (i), (ii) or both] decree. because _ (i) The parties to this action have not lived separate and apart for a period of at least two years. _(ii) The marriage is not irretrievably broken. 2. Check either (a) J (a) or (b): _(b) I do not wish to make any claims for economic relief. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I wish to claim economic relief which may include alimony, division or property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. I verify that the statements made in this counter- affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification authorities. Date: o~/ 2m5D to / ..S. # oN" - 2r~~~) 4:> NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make any claim for economic relief, you need not file this counter-affidavit. (") c 0 c:::: <:::> -.-, -as.: Ite -~ w .,.., ~[J] ..'" -~ r-r:'r2 ::;::?'_'..J J '--n't 65;;;: ::';OS? ;:s~ '---' :s: v ;';:1i~ :€o =>: -"- :ri 90 :;;;:0 ':? ---m ~ q r\:> {ig UI -<: '- '" Plaintiff IN THE COURT OF COMMON PLEAS : CurnJ:ierland . County, PENNSYLVANIA CIVIL DIVISION - LAW IN DIVORCE MARK K. KICHMAN, vs. JOYCE M. KICHMAN, Defendant : : No. 2000-01736 Civil ACCEPTANCE OF SERVICE I accept service of PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE, DEFENDANT'S COUNTER- AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE COMPLAINT, and the NOTICE OF INTENTION TO REQUEST ENTRY OF SECTION 3301(d) DIVORCE DECREE. Date: /Jfj ~ 2o'Od ichman, Defendant 390 Me.-I4eI'u"J kc/ +>), cJ f4f} ;(CUt lif _ jJ/f" r9 l' fd) (Mailing Address) ..,. A MARK K. KICHMAN, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : VS. : CIVIL DIVISION - LAW : IN DIVORCE JOYCE M. KICHMAN, : Defendant : No. 2000-01736 Civil NOTICE OF INTENTION TO REQUEST ENTRY OF SECTION 3301(d) DIVORCE DECREE To: Joyce M. Kichman 390 pickering Road Phoenixville, PA 19460 Defendant You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the Section 3301(d) affidavit. Therefore, on or after May 28, 2000, the other party can request the court to enter a final decree in divorce. If you do not file with the prothonotary of the court an answ-er with your signature notarized or verified or a counter-affidavit by the above date, the court can enter a final decree in divorce. A counter-affidavit which you may file with the prothonotary of the court is attached to this notice. . Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Lawyer Referral Service of The York County Bar Association The York County Bar Center 137 East Market Street York, Pa 17401 Telephone: (717} 854-8755 ',_,_ .J< c DEFENDANT'S COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): (a) I do not oppose the entry of a divorce decree. ----(b) I oppose the entry of a divorce decree because [Check (i), (ii) or both] ____ (i) The parties to this action have not lived separate and apart for a period of at least two years. ____(ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): ____(a) I do not wish to make any claims for economic relief. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. . ____(b) I wish to claim economic relief which may include alimony, division or property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. I verify that the statements made in this counter- affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: . Defendant S.S.lI NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make any claim for economic relief, you need not file this counter-affidavit. '-- ..,. Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA MARK KICHMAN, : vs. : CIVIL DIVISION - LAW : IN DIVORCE JOYCE M. KICHMAN, Defendant " : No. 2000-01736 Civil (") C ~ o o " :3 .-,;-;.';.; :,;:.... -':-il::O ''':.. --<. ,'.,..-- ;?~ '& "~J;11 ..._1.. . ~~;:9 If you wish to deny any of the statements set DQith In .~o this Affidavit, you must file a counteraffidavit withi~~enty S~ (20) days after this Affidavit has been served on you qi;f:.the:- ,z~ statements will be admitted. ?s::; ":? ~.~ ~ ;; -< NOTICE TO THE DEFENDANT PLAINTIFF'S AFFIDAVIT UNDER SECTION 330l(d) OF TEE DIVORCE CODE 1. The parties to this action separated on March 1, 1997 and have continued to live separate and apart for a period of at least two (2) years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony , division of property, lawyer's fees or expenses' if I do not claim them before a divorce is granted. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 19 Pa. e.s. Sec. 4904 relating to.unsworn falsification to authorities. Date: May 8, 2000 r;;( ~r-~ Plaintif " . (") 0 0 c: = ..~ ~ ;:: ~ -~ -oD"J ,- rngj :-~1 ;:2 :2' ..,....t'11 zc "'9 ~z Oi,:..J ~CJ --u :J:=ri ~(") ;:ll:. ~~B 5"0 ~ om c: "'"I' ~. N .". W ~